GUIDELINES FOR MAKING PRODUCT CLAIMS

This practical guide to making claims provides valuable information for Independent Business Owners (IBOS) to use in their everyday

operations. It describes various types of claims and provides simple guidelines for making claims that are likely to be

approved by ACN.

Educating yourself and others in your

organization is key when it comes to building

your business on a solid foundation.

2 ACN Guidelines For Making Product Claims

3ACN Guidelines For Making Product Claims

Anume products are foods, dietary supplements or cosmetics. Product claims

are statements that describe what a product can do; what it is for and what

benefits it provides. You may only make claims that appear on Anume product

labels, features and benefits, catalogs, and websites. ACN has approved only

these claims. It is important that you never deviate from these authorized claims

in making product claims.

REMEMBER: Even though you may have obtained results that are “better

than” or “different from” those stated in Anume materials, you cannot say so.

This is because:

• Certain claims are not permitted for certain kinds of products under

FDA/FTC regulations.

A dietary supplement is a product that contains a dietary ingredient intended

to add further nutritional value to (supplement) the diet. Dietary ingredients

include substances like vitamins, minerals, amino acids, or extracts. The Dietary

Supplement Health and Education Act of 1994 (“DSHEA”) requires the following

declaration, also known as the DSHEA statement, to be used in all labeling and

promotion of dietary supplements:

PRODUCT CLAIMS

REQUIRED DSHEA STATEMENT

This declaration is intended to help consumers avoid confusing the benefits of

a dietary supplement to the actions of a drug. If you see this declaration with an

authorized claim on any approved materials, website or catalog, you must use it

any time you make the same claim in writing.

This statement has not been evaluated by the Food and Drug

Administration (FDA). This product is not intended to diagnose, treat,

cure or prevent any disease.

4 ACN Guidelines For Making Product Claims

The following is an example of what not to say:

TYPES OF CLAIMS

DIRECTIONS FOR PRODUCT USE

DISEASE CLAIMS

Disease claims are those that state or suggest that a product will treat, prevent or cure a

disease or other medical condition. All claims of this kind are strictly prohibited.

You must never encourage a customer to take more

than the recommended daily amount of any product,

or otherwise use the product in a way that conflicts

with the instructions for use on the product label.

If you adhere to the recommended dose on the

product label, you can feel confident when explaining

product usage.

REMEMBER: The label is your best guide!

Vita+ provides calcium. Because of the calcium in this product, you don’t have to ever

worry about osteoporosis -or- Because of the calcium in this product, it will treat the

symptoms of osteoporosis and you will no longer suffer.

Remember that all statements and claims made about Anume products must be consistent with

the instructions for use on the product label.

5ACN Guidelines For Making Product Claims

WEIGHT-LOSS CLAIMS AND WEIGHT-LOSS DISCLAIMER

It is well established that losing weight requires burning more calories than you

take in – either through reducing your caloric intake, increasing the amount of

calories you burn, or preferably, both. Anume weight-management program

is based on products that help people reduce caloric intake, along with

incorporating a sensible diet and physical activity.

You can make claims about weight-loss results achieved through Anume.

However, all claims that you make:

• MUST include reference to lowering caloric intake, eating a balanced diet

consisting of healthy foods and engaging in regular physical activity;

• MUST be truthful, accurate and not misleading;

If you are making a weight-loss claim in writing, such as a presentation, written

materials that contain weight-loss claims, or posting a before-and-after

picture, you must use the full text of the weight-loss disclaimer:

“Results not typical. Diet and exercise required. Average consumer

may lose 1.5-2 pounds per week.”

Disclaimers are updated from time to time, so remember to use the current

disclaimer. For the most up-to-date disclaimers, visit ACN Compass. Keep in

mind, using “Results not typical” or “Your results will vary” alone is not sufficient

and does not comply with ACN Rules or the law.

6 ACN Guidelines For Making Product Claims

UNACCEPTABLE WEIGHT LOSS CLAIMS

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The Federal Trade Commission considers the following seven “gut-check”

claims to be false or misleading in all promotions or advertisements for weight

loss or weight management programs. They are:

Claims like the above, or any variation of the above, are strictly prohibited. Anume products

are cutting-edge and do not require such exaggerations or any claims that deviate from those

approved by ACN, which can be found in current product features/ benefits and catalogs.

A product or program will promote weight loss without dieting

or exercise.

A product or program will promote substantial weight loss no matter

what or how much the consumer eats.

A product or program will cause permanent weight loss even after

the consumer stops using product.

A product or program will block the absorption of fat or calories to

enable consumers to lose substantial weight.

A product or program will allow consumers to lose more than 2.5

pounds per week safely.

A product or program will cause substantial weight loss for all users.

A product will cause substantial weight loss by wearing it on the

body or rubbing it into the skin.

7ACN Guidelines For Making Product Claims

PRODUCT CLAIMS

PERMITTED STATEMENT

PERMITTED STATEMENT

PROHIBITED STATEMENT

“I take Shake-it! every morning for

breakfast to get protein, vitamins and

minerals my body needs.”

“I did the Anume 21 Day Challenge 3 times [during the last X months,

or consistently, whichever explains your story] and I was able to lose

10 pounds and 5 inches by using the product, changing my diet and

working out daily/hours per day/etc.”

“I did the Anume 21 Day Challenge 4 times and lost 12 pounds and went

from size 14 to a size 10 using the products, eating a balanced diet

by eliminating junk food, and adding walks to my daily (or whatever

explains how many times and how long you walked for) routine”

“I take Shake-it! every morning

because since I started taking it, I have

stopped having problems with my

diabetes and migraines!”

EXAMPLE 1

EXAMPLE 2

There is no approved diabetes or migraine disease claim for Shake-it! and these statements

make it appear to be a drug product.

8 ACN Guidelines For Making Product Claims

PERMITTED STATEMENT

“Momentum helps me get through the day. I feel

energized and can keep up with my kids. I feel great!”

“I did the 21- Day Challenge X times and I now feel I have better eating

habits and make better food choices. Because of combining Anume’s

Weight Management System (Shake-it!, Go! and Sync!) with a nutritious

diet and lifestyle changes, I feel healthier, full of energy and ready to

tackle the day. Shake-it! makes me feel fuller longer, which I believe

helps me make better food choices.”

EXAMPLE 3

EXAMPLE 4

PRODUCT CLAIMS

SIZE AND PLACEMENT OF REQUIRED DISCLAIMERS

The use, size and placement of a disclaimer is as important as the claim that is made. Disclaimers

must always be clear and conspicuous, which means that they must be easy to see, read and

understand by the average consumer and be in a font that is at least as large as other fonts used

to convey the claim. Some things to keep in mind with disclaimer use:

The placement of the disclosure and its

proximity to the claim it is qualifying (do you

have to scroll, is it easily seen?)

Whether creative content of your marketing

material distracts the consumers attention

away from the disclosure (claim and/or

pictures so big the disclaimer can’t be found)

Whether your claim is so lengthy that the

disclaimer needs to be repeated (remember

close proximity)

Whether the language of the disclosure or

disclaimer is understandable to the intended

audience (Keep it simple with all necessary

info).

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If you are keeping these things in mind when marketing the Anume products, you are on the right path.

9ACN Guidelines For Making Product Claims

FOR SIMPLICITY, DISCLAIMERS MUST BE:

Size and placement requirements for disclaimers apply to all forms of promotion dissemination;

live or taped presentations, social media, as well as written materials. If a claim is made orally

as part of a presentation on stage or in a video, the disclaimer must be audible and provided as

close to the claim as possible.

Any written disclaimers in videos should follow the guidelines above for disclaimers in written

materials. They should also remain on screen long enough to be noticed, read and understood.

If disclaimers are hard to find, tough to understand, obscured by other elements in the ad or

buried in unrelated details, they don’t meet the clear and conspicuous standard.

Easy to read, easy to understand and easily found

In a minimum font size of 10-point. Please keep the size of your

claim in mind, when assessing the size of your disclaimer

In a font color that stands out against the background (for

example, white on dark blue or black, not white on light gray)

Easy to find (not buried in a footnote or a block of text that

people aren’t likely to read or where scrolling is needed to find

the disclaimer)

Close to the claim to which the disclaimer relates

10 ACN Guidelines For Making Product Claims

21 DAY CHALLENGE TESTIMONIALS SUBMISSION

You must receive written approval from ACN prior to making claims about your individual

experiences or that of your customers with the Anume21 Day Challenge. This includes express

and implied claims (written and images). To submit your testimonial, please:

ACN will contact you within 10 business days to indicate whether your submission has been

approved. Submissions that are not approved may not be used.

Use of unapproved materials may result in action on your position, up to and including

termination, in ACN’s sole discretion.

Visit the 21 Day Challenge website at www.anumereto21.com

Go to the testimonials page and complete all required fields

Upload any images or other materials you would like to use

Agree to the Terms and Conditions associated with your

testimonial and submit it

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11ACN Guidelines For Making Product Claims

BEFORE AND AFTER PHOTOSImages can be influential and persuasive to the consumer.

They make implied claims about the Anume weight-

management program, as they show how people’s bodies

changed while they were using the products, whether it be

in terms of pounds lost, inches lost or changes in body fat.

Photos and any assertions that accompany the pictures are

held to the same standard as other claims.

Take a before picture of yourself prior to starting the

Anume 21-Day Challenge

Take an after picture of yourself using the same location, lighting, and type

of clothing

Same position (side, forward, back)

Same portion of the body shown (upper, lower or full)

Submit for approval

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Therefore, before-and-after pictures must always be accompanied by the above referenced

weight-loss disclaimer. Prior to posting any photos to social media (including but not limited to

Facebook, Instagram, Twitter, Vimeo, YouTube), the testimonial must be reviewed and approved.

Please do not post or “share” before and after results without obtaining ACN’s prior

authorization.

Please send all requests for approval through our website www.anumereto21.com

Please note, any photos that do not comply with the below requirements, will likely not

be approved and should not be used for promotion of the Anume weight management

program.

BEST CASE SCENARIO PHOTO REQUIREMENTS

12 ACN Guidelines For Making Product Claims

Also please keep in mind, if you only participated in the program for 21-days

and provide a before and after depiction with a drastic result (i.e., obvious weight

loss over the average), we will be unable to approve the photo for use, as we will

be adhering to the guidelines set forth by governmental agencies.

As such, photos representing results of this kind are not permitted to promote

the program, therefore please do not post them in social media.

If it is found that you have posted photos or commentary that is either not

approved or not part of approved product information, sanctions may be

imposed up to and including termination of your ACN distributorship.

APPROVED EXAMPLE:

*For illustration purposes only

GUIDELINES FOR MAKING PRODUCT CLAIMS